Thematic Review on Source of Funds (“SOF”) / Source of Wealth (“SOW”) in the Private Wealth Management sector
The Commission has issued its report on the thematic review of SOF / SOW in Guernsey’s private wealth management sector. The review was undertaken during the second half of 2019.
A copy of the thematic review can be found by clicking here.
The Commission encourages all firms, regardless of their sector, to undertake the following steps at the commencement of the relationship and when significant new funds are received:
- Ascertain at the outset how the customer generated his or her total net worth and that of the particular funds to be used in the business relationship or transaction;
- Take into account the various risk-factors present within the relationship (including customer, country, product/service and deliver channel risks, and their cumulative impact) in considering the extent to which this information should be corroborated by further information and official documentation from the customer, appropriate third parties and/or independent open source information,
- Finally, consider if this make sense against what the firm knows about the customer and the intended purpose and rationale for the business relationship or occasional transaction.
To view this notification in full, please click here.
Please be advised that under Council Implementing Regulation (EU) 2020/1124, the EU has added French national Bryan D’Ancona to the EU’s autonomous sanctions regime, which targets those determined to be associated with or providing support